>>SPEAKER: Good afternoon ladies and
gentlemen, my name is Lynn Banks from
the US customs and border protection
office of trade and relations. Thank
you for joining us today for the Never
Screw Fasteners of 7318 Again! Webinar.
Today's webinar is part of the 2023
educations commodity specific webinar
series and it has an expected duration
of 90 minutes.
We have a few housekeeping items,
everybody will be kept on mute during the
presentations so that we can keep the
line clear of any background noise. If
you have any questions or comments, we
invite you to type them into the
chatterbox at any time during the
presentation. We will answer as many
questions as we can from the chat box
at the end of the presentation and the
continuing education credit code will be
placed in the WebEx chat box during the
presentation. Today's presenter is
national import specialist Jennifer
Jamison, Mr. Jamieson, over to you!
>>SPEAKER: Thank you, hello everyone
and that afternoon and good morning,
thank you for being here. I would like
to welcome you on behalf of the CPP
office of trade and the national
commodity specialist division. I am
Jennifer Jamison and I am the national
import specialist for a line that
includes base metal goods such as
fasteners, mountings and fittings,
locks, safes and ornamental articles.
Today, I am going to be talking about the
classification of fasteners of heading
7318. This presentation should last
about 60 minutes and you can post
questions in the chat box and I will try
my best to answer them as I see them,
but to be honest this is new for me and
I will adjust accordingly. I will also
have time at the end for questions on
anything on the presentation.
So, here are the mission statements for
both CPP and the office of trade. The
intent of this webinar is to facilitate
the correct entry of merchandise into
the United States and thereby help
achieve one of our office of the trade
missions.
This disclaimer let's see now that this
webinar is advisory only and not
binding. As you all know, I am sure,
classification can be really complex and
there is a lot of factors to consider so
reliant solely on the general
information that is included today may
not be considered reasonable care.
I have included a lot of photos in this
presentation to show as examples of the
fasteners and the details that we are
discussing. All of the photos are in the
public domain and if any brands are
identifiable, their inclusion in this
presentation does not represent an
endorsement or approval by CBP, they are
purely included to show you the best
examples of the topic that is being
covered. I
am hoping that this presentation will
provide you with a lot
with a lot of helpful information, but as
I just mentioned, there is a lot of
complicated factors that can be involved
in the classification of merchandise.
So, I want to remind you about the
binding ruling program that allows you
to get a binding classification
determination for a specific product.
You can apply for the ruling using the
website that is listed on your screen.
It is free and you should get a
response within 30 days and you will get
a classification that you can use at any
port in the United States.
If you do request a binding ruling
classification, please include as much
information as possible so we can
determine the classification. And that
would include information like the
country of origin, maybe send a sample
or a picture or technical drawings or
links to website about the item. We
need to know what the article is made
of, if it is a composite good, we need
may be a value and weight breakdown and
how it functions, where it is used, that
kind of thing.
So, I have got a lot of information to
cover today, so I am going to go quickly
through some of the more straightforward
sections so that I can focus more time
on some of the more tricky ones. But,
please know that you will have access to
these slides when this presentation is
posted and it is going to be posted at
the link in this slide here. And it is
my understanding that it will be
available in about two or three weeks.
So, let's get started. Having 7318
covers screws, bolts, nuts, coach
screws, screw hooks, rivets, corridors,
cotter pins, washers and similar
articles of iron or steel. So, if a
fastener is made of something other than
iron or steel, then it will be
classified under the chapter for that
material. So, for example screws made of
copper would be classified in chapter 74
and screws made of aluminum would be
classified in chapter 76.
The explanatory notes identify that all
of these items are used to assemble or
fasten goods that they can be readily
disassembled without damage. So, to be
classified in 7318, the item needs to
have a fastening function. This heading
is divided into two main sections.
We have got the threaded articles and
then the non-threaded articles. So,
before we get into the specifics of
7318, I want to start with some
definitions and information that covers
the whole heading. And if the first
thing that I want everyone to know is
that everything is class - everything
that is classified under 7318 is
considered to be parts of general use.
So, I want to give you a very quick recap
of what that means.
The topic parts of general use is its own
60 minute training webinar. I did one
of those in 2019 and you can review it
online if you want more details, but
here are some key parts that I want you
to keep in mind for today's webinar.
Parts of general use are defined in
section 15 note 2 and note 2A is where
it specifies 7318 and similar articles
of other base metals are considered part
of general use. So, as I mentioned
before, fasteners that are made of
material other than iron or steel are
classified by their constituent
material. So, a screw that is made of
copper would be classified in chapter
74, but because that copper screw is
similar to a screw of 7318, it would
still be considered a part of general
use.
Explanatory note C to section 15 explains
that part of general use when entered
separately are not classified as a part
of an article. Instead, they would be
classified in the appropriate heading in
section 15 which includes heading 7318.
The notes from section 16 and 17 and
chapters 90 - 96 tell us that if we are
classifying an article that is considered
a part of general use, if it is entered
separately, it is excluded from
classification in those sections and
chapters. So, based on this information,
if an item can be classified as a part
of general use, it is excluded from
classification under section 16 and 17
which covers chapters 84 through 89 and
also excluded for chapters 90 through
96.
And lastly I want to also note a common
misunderstanding of the CBP term "general
use ". A lot of people think because an
item is made or designed for a very
specific application then it is a part of
that application, because it is not for
general use. It is for specific use.
For example, if a screw is made for a
very specific part of a motor vehicle,
then one might argue it is a part of that
motor vehicle because it is specifically
made for it. But, the term general use
as defined by CBP here refer to the
class of articles. The class is a
general, but the articles can be
specific. And items that are described
under heading 7318 are considered a
general use class of item. So, even if
the screw is very specifically made for
and only for use in a specific
application, if it can be classified
under 7318, and it is presented
separately, it would meet the terms of
heading 7318 and be classified in 7318
and not be a part of the application.
And I have an example of that that I
will go over later in this
presentation.
And again, if you want more information
specifically on parts of general use, you
can check it out at this link, it is
where all of the webinars live. This
one was in 2019, so I believe they are
sorted by year and it is located under
the industrial and manufacturing
materials section.
Heading 7318 includes both screws and
bolts. There is an informed compliance
obligation or ICP for short called
distinguishing bolts from screws making
the distinction between a bolt and a
screw. Now, I will not have time to go
through all of these details in this
presentation, but I do want to touch on a
few areas. But, for more information,
check out that ICP.
CBP uses the American National standards
Inst. Or ANSI for short and the
American Society of American engineers
or ASME for short to distinguish bolts
from screws and the standard in
particular that I'm looking at here is
identified as B 18.2.1. And that
standard states that both Olson and
screws are externally threaded fasteners.
A bolt is designed to be threaded
through holes in assemble parts and
normally intended to be heightened or
released by torquing a nut. A screw is
designed to be inserted into holes in
separate parts, but it can marry up with
a preformed internal thread or form its
own thread. And a screw is tightened or
released by torquing the head. Now,
because of the basic design, it is
possible to use certain screws in
combination with a nut. So the presence
of a nut does not help us in the
classification, but any externally
threaded fastener which has the majority
of design characteristics that help a
fastener to be used in a tapped or
preformed hole is a screw regardless how
it is used in its surface application.
And those additional design
characteristics are discussed and that
distinction bolts from screws ICP, so
please refer to that when making a
determination.
I want to point out that as of today, all
of the fasteners of 7318 that originate
in China are subject to an additional
section 301 trade remedies. Nuts are
subject to one case and all of the other
fasteners are subject to another. Rather
than keep mentioning that, I have added
a small red flag on each slide to
remind you that 301 trade remedies apply
for goods from China. You can check the
latest tariff to verify the trade
remedy details, but as of today, nuts
from China are subject to an additional
7.5% trade remedies and all other
fasteners from China are subject to an
additional 25%.
Also, there are a few anti-dumping and
countervailing duty cases to keep in
mind. They are for threaded rod and
helical spring lock washers. I will
mention these again when we come to
those products. I will not have time to
get into the cases specifically, but I
want to remind you that these cases are
in place for these products from these
countries.
Okay, so let's get into 7318. To be
threaded, as I mentioned earlier it
starts with a threaded article and to be
threaded, the fastener must have a
complete thread. And a complete thread
is designed as a ridge of uniform
section in the form of a helix where the
external or internal surface of the
cylinder. So, what you need to know is
that it needs a complete thread in a
spiral form, think like a slinky in that
form.
This fasteners looks like it might be
threaded, but it actually has annular
grooves, it does not have threads not
form a helix, because of that, this
fastener would be considered
non-threaded.
And of these examples look non-threaded,
but they are actually incomplete or
unfinished hex head steel Screws and
they would be considered threaded based
on GRI 2A based on the classification of
goods that are incomplete or
unfinished. .
So, let's get the subheadings. The first
one provides for coach screws. Coach
screws are large heavy-duty wood screws
that have a square or a hex dog and all
head and they are on slotted. The coach
screws have a steep cutting threads and
they cannot accommodate him not. Coach
screws are also known as screw spikes,
lag screws and lag bolts. And they are
used to fix railroad lines or to a
sample rafters or similar heavy
woodwork.
7318.12 provides for other wood screws.
Wood screws can resemble self tapping
screws and they can be tricky. In 2018 ,
the core of international trade decided
a case that considered if a few specific
fasteners were wood screws or self
tapping screws. That case was GRK
Canada vs. United States. And that case
has given us this definition of a wood
screw. It is "unscrew that forms its
own threads by compressing surrounding
material designed to fasten would to wood
or the other fibrous material. "
There are two key parts of this
definition. First, it is a screw that
forms its own threads by compressing
surrounding material and two it is used
to fasten would to wood or other fibrous
materials. Starting with the second one
first as you might expect, they are used
for plywood, lumber or other types of
fibrous material. But, just because a
screw is used to fasten wood material is
not enough to call it a wood screw. You
need to look at the attributes of the
actual screw. So, let's take a look at
some of those attributes. We will start
with the first points that are listed in
this definition that a wood screw forms
its own threads by compressing
surrounding material.
In order to form its own threads, wood
screws bite their way into the wood.
And to be able to do that, wood screws
are generally tapered and they will
always have a gimlet point which is a
sharp tone point with threads, you can
see how sharp that is and that threads
go all the way down the point. Wood
screws also have steep cutting threads
which are wider, deeper ridges. When
the screw is inserted into wood, the
material that it is displacing as it
bites its way through generally stays
inside the wood and those course threads
inside the screw in addition to helping
bite through the material it also
provides space to hold the material that
is being pushed out of the way as the
screw enters the wood. Wood screws
generally have fewer threads per inch
than a tapping screw. They are usually
threaded along two thirds of the shank,
they almost always have slotted or
processed heads and because of the point
in tapering that they have, they cannot
take a nut.
Now, I will compare wood screws and self
tapping screws in a moment, but I will
continue down the tariff and cover hooks
and rings and before I move onto that I
see there is a message about showing
another slide and I think rather than
just to go back I will show you those
again at the end of the presentation.
So, screw hooks and rings are provided
for in 73 18.13. They are used to
suspend or fasten other objects and as
you can see here, one end is bent into
an angle or a hook or a ring and the
other side has a gimlet point and steep
cutting threads. These screw hooks and
rings will not accommodate A nut. And
let's dive into self tapping screws that
are covered in 73 18.14.
So,
a tap is something that can be inserted
into a whole and create a threading for
the screw to fasten into. But, self
tapping screws and cut their own way
into the material and they do not need
that. They can pierce thin metals and
dig into the material to cut their own
threads. Unlike wood screws that
compress the surrounding aerial, tapping
screws cut the material that they are
being fastened into. So, let's take a
look at the CIT definition of a self
tapping screw from that same court case,
GRK Canada vs. the United States.
It says "a self tapping screws is a
specially hardened screw that meets
minimum torsional strength
requirements, that can cut away material
to form a mating thread in non-fibrous
materials and is designed to fasten
non-fibrous materials, such as metal to
either fibrous or non-fibrous materials."
So, that is a lot to unpack in that
definition, so let's start breaking them
down separately.
First, it says that self tapping screws
are specially hardened and meet minimum
torsional strength requirements. These,
of course are not attributes that you
would be able to see on the actual
fastener, but that information would
likely be noted on the technical drawing.
Self tapping screws need to be strong
to cut their way into really hard
materials, so they may be designed to be
coated with materials that provide extra
hardening and strength. They are also
designed to meet minimum torsional
strength requirements which means the
ability of the screw to with they had a
twisting load as they are twisted and
forced into the material.
Then, the definition says that self
tapping screws can cut away material to
form a mating thread. When it cuts away
material, that material will be removed
when the screw is inserted and you will
likely get chips of that material that
you are installing into. And lastly,
self tapping screws are designed to
fasten non-fibrous materials such as
metal to either fibrous materials such
as wood or two other non-fibrous
materials. So, they can be used to
fasten into harder materials like thin
sheets of metal, marble, slate, plastics,
etc., but they can also be used in wood
applications.
ICA chat, is there an easy way to
calculate the thread shank diameter that
is a part of the code? We talk about
the diameter with machine screws, so I
will hold off on that question. In the
meantime, let's take a look at the
visible characteristics of self tapping
screws.
Self tapping screws have a tapered or
pointed end. They can have course
threading or they can have fine threading
with specialized points. They are
usually threaded along the entire length
and they generally have more rads per
inch than a wood screw. They have
slotted, recessed or wrenching heads and
they are available in various thread and
point styles and I will show you that on
the next slide and they cannot take a
nut. So, here are some examples of self
tapping screws, this topic screw here is
actually a drywall screw, it has a bugle
head, it has a gimlet point and it has a
steep cutting thread. Customs has
routinely classified drywall screws as
tapping screws. This example here, you
can see has a triangular point and this
one here has a drill point.
And a table comparing self tapping screws
vs. wood screws, I have a chart coming
up. So, tapping screws have a
specialized points such as these. The
tapping screws that have a B designation
like in this column, they all have a B
in their designation, those are going to
have steep pitched threading. And
generally, the tapping screws without the
B designation these ones on the
right-hand side, they are going to have
machine screw threading which is fine
threading, but they will have a point
design that makes them capable of
cutting through material and forming
threads like a drilled point or slotted
point or triangular point or fluted.
So, as you can see, wood screws and a
self tapping screws can be pretty
similar and I put this chart together
just using information that we have
already covered to compare and contrast
wood screws and tapping screws. The key
point that I want to stress is that when
you are looking at a screw, whether it
be a wood screw or a self tapping screw,
do not just consider what it is fastened
into. Also, look for these
characteristics that indicate that it
might be a self tapping screws such as,
it is specially hardened, it meets
minimum torsional strength requirements,
it is designed to fashion non-fibrous
materials like metal to either fibrous or
non-fibrous materials. And again, those
three things are not something that you
can see on the screw itself, so it is
information that is likely available on
the technical diagram. So, I recommend
viewing that and I would also recommend
reviewing the standard to which the
screw is designed.
I will leave that on for a second. I
guess before we move onto the next
section, does anybody have any questions
about the wood or tapping screws? Okay,
I am not being any come in right now,
again you will have time to ask
questions at the end.
I will hold off on page 22 until the end.
I will move on now to other screws and
bolts that are classified under 7318.15.
73 18.15.20 covers bolts and bolts and
their nuts or washers entered or
exported in the same shipment. These are
member that a fastener can be called a
bolt, but if the fastener has a majority
of the design characteristics of a screw,
then it is a screw, regardless of how it
is used in its service application.
Again, please refer to that
distinguishing bolts from screws ICP and
the characteristics to look for, but this
is where you would classify a true
bolt.
Generally, alts are designed to be
tightened or released by torquing a nut.
They are cylindrical in shape, they
rarely have a point, they have close
thread with a slight incline and usually
a part of the shank is unthreaded. The
tariff starts breaking out a few
specific alts, the first one is for
tractor bolts. They have a mushroom
shaped head and either an oval or
elliptical neck. Track bolts are used
as rail fasteners and sometimes referred
to as a rail bolt.
73 18.15.2030 covers structural bolts and
these are really heavy duty both that
are used in applications like building
structures and you can identify these,
because they will have the ASTM standard
to which they are built stamped right on
the head. So, look for either letter
A320 fives or A4 90 stamped on the head
and you will know that it is a
structural bolts.
Under 73 18.15.2041 bent bolts, there are
two breakouts, first art right angle
bolts which are self explanatory. And
remember this section is for bolts and
nuts and washers supported in the same
shipment, so for this first example, if
the knot, washer and all right angle
bolts are all imported in the same
shipment, they are classified as a right
angle bolts. Is it safe to distinguish
a vote from a screw is if the heads are
going up more than halfway and not to
what the bolt is being used in? The
length of the thread is not enough to
distinguish it. Again, that will be
something that I will ask you to look at
that distinguishing nuts from volts ICP,
because there are some specific
attributes to look for, but the length of
the thread would not help you out in
that determination.
And yes, as you will see in the next one,
a U bolt is a bent bolts. Other bent
bolts are classified under 7318. 15.
2046. And this would include fasteners
like eye bolts, U bolts and hook bolts
and if the nuts are entered in the same
shipments, they are classified with these
other bent bolts. I just wanted to
point out that these two items that we
have discussed a look very similar, the
first one is a eye bolt, it has a blunt
fit and used with a nut, that is
classified under 73 18.15.20 as a bent
bolts, but the second one here looks
very similar, but it has a gimlet screw
point and you could not use a nut with
this one. This one is classified as a
screw ring under 7318.13. So, if you
have these rings, look for the type of
point on those.
And I also want to point out the
difference between a eye bolt of 7318
and a shouldered eye bolt, 7318 has a
fastening function where is this
shouldered eye bolt has a forged full
circle here, this has a lifting function
and the lifting eye bolt would be
classified by its constituent material,
it would not be classified in 7318,
because it does not have a fastening
function.
Now we are moving further down this same
subheading of other screws and bolts
whether or not they are with nuts or
washers and 73 18.15.40 provides for
machine screws that are 9.5 mm or more in
length and 3.2 mm or more in diameter
and not including cap screws. So, for
machine screws we start with measurement
parameters. The length of a screw or
bolt is measured from the point to the
area where it would flush on the surface
after installation. So, from the point
to where it is going to be sitting where
it is fastened into the material, that
is the length we are measuring. And
there was a question about measuring the
diameter and I have a little tool to
measure the diameter, so I don't have
another idea right off the top of my
head of how to best measure that, sorry
about that.
So, let's see, the length and the
diameter of the machine screw is pretty
much all we get in the guidance terrace
for what is a machine screw, so we will
look at the industry standards for more
details.
The other types of screws that we have
looked at so far have tapered ends and
pointed tips, but Sheen screws have a
uniform diameter along the entire length
of the shaft and a blunt point taking
them look very similar to bolts. These
screws are torqued by the head, but
typically threaded through pre-existing
capital holes and used with a nut. Sheen
screws are typically designed with a
finer more accurate threads than other
fastener types and they are used to
fasten metal to metal or metal the
plastic. These are the attributes of
the machine screw, but let's go back to
the subheading language. Okay, so the
question is do you measure from the
outside of the thread or the Valley? I
measure from the outside of the thread.
Can you show where you would measure
the diameter? I would measure like on
this example I would measure the
diameter anywhere right in here on the
shank of the screw. Thank you, I cannot
think of the word, the micrometer is what
I used to measure the diameter and I
have always had one, so I don't have
another means to measure them.
Okay, I think that is all of the
questions. So, we are going to go back
now and look at the attributes - we are
going to go back to the subheading
language on machine screws. After we
talk about the length and diameter
parameters, the subheading reads " not
including cap screws " so, let's take a
look at what that is. For
classification purposes, cap screws are
fasteners with a tax head with a washer
phase or its equivalent, so let's take a
look at what that means.
Customs has a long-standing practice for
distinguishing machine screws from cap
screws based on the presence of a washer
phase or its equivalent on the underside
of the head. And this came from the
heads and threads vs. United States
court case in 1969 which said that a
hexagon head cap screw is this a gradual
from screws by the presence of a washer
phase which is in a Boston circle which
is also called a boss and you can see it
right here under the head of this screw,
it is that little raised circle under
there, that would be a washer phase. It
can have a washer phase or its
equivalent and there are two of those,
the hexagon screw can have chamfered
corners on the underside of the head and
you can see examples here of the
chamfered corners and they are softened
here so the points of the hex head do
not gouge into whatever you are
fastening into. And the other equivalent
would be a phalange or washer head that
is attached on the screw that would be
considered also a washer head
equivalent. The purpose of a washer
phase is to give the fastener a smooth
bearing service the prevalent the points
of the fastener head to affect the work
that they are being fastened into. So
with these attributes it would not be
classified as a machine screw. ICA
question, how do they differ from
structural bolts that have a washer
phase? Structural bolts are generally
much larger and sturdier bolt than a
machine screw which tend to be finer and
actually they have those measurement
requirements, so I don't have another
example. I would have to think if I can
come up with another example there.
But, here is an example from a
headquarters ruling that I wanted to
mention, this has a hex head with a
phalange head, but there are serrations
on the underside of the flange. Because
those serrations prevent this fastener
from having a smooth bearing surface
under the head, it is not considered a
washer phase equivalent and this example
was classified as a machine screw.
Duds are defined as dreaded fasteners
with one and anchored or fixed in place
to provide a projection to which
something may be attached by a nut or
other fastener. They can be threaded at
each end, they can be fully threaded or
they can have ahead. They can also not
be bent as long as they meet this above
definition. This is a hanger bolt and
you can see this one and has wood screw
threading and at the other and it has
machine threading here. So, when the
hanger bolt is fixed in place, this
machine threading section extends out and
allows for something to be attached with
the use of a nut. And this ribbed neck
is what allows the fastener to be
anchored in place and then once that is
anchored, this threaded projection
allows for a nut to be attached.
There are several anti-dumping and
countervailing duty cases four threaded
rods from China, India, Thailand and
Taiwan. So, if you have an article
classified as a stud from any of these
countries, check to see if any of these
cases apply.
There is a question in the box, what is
considered a preformed hole for
classification purposes? I do not
really understand that, a whole is not
classified, it would just be the whole
like if you are trying to put a wood
screw into a piece of wood and they put
a little pilot hole in so that the
fastener has thread to thread into it,
that would be the preformed hole that I
am talking about. If I am missing the
question, if you can let me know again
and clarify that. And the next question
is when you see a description of screws
like M4 or M5, does not give you any help
to the thread diameter measurement?
Yes. That does, that is a metric and
there is a table that you can look up to
see what the diameter is of a M4 or M5
or M6 and same thing for a 3/8 inch
screw, yes, I would say I believe the 3/8
inch is the diameter of that. Again,
that is really more in the
distinguishing bolts from screws section,
so I believe that is correct. but it is
not included in here.
The next question is if something is
imported with fasteners usually not
known or shown on an invoice but may be
subject to dumping, would they be
required to separated out and declared
separately? And you give me an example
of what you're talking about with that
if it is important with fasteners - so,
if you are bringing in a kit or
something and that kit includes the
fasteners to put it together, the
fasteners are just included with the
kit, so I'm trying to think if I am just
classifying fasteners, what else may be
included with it that would be required
to be separated out and declared? Okay,
so furniture or other items that need
assembly. Yes, so it would not be
classified by the fasteners if you are
importing furniture and it includes the
fasteners, you'd be classifying it by the
furniture, not by the fasteners. So, we
would not have to separate those out -
are you saying if I am bringing in
furniture and the fastener has
anti-dumping? I am sorry, I bet that is
what you are asking. I don't believe it
needs to be separated out, I am going to
have to check on that. I do not believe
so, but I would like to double check
that before I give you an official
answer on that. That is a good
question. Okay, let me move forward.
Okay, I want to move along to the other
subheading under other screws or else and
there nuts and washers and 73 18.15.60
includes other goods that are less than
6 mm in diameter. And the 73 18.15.80
includes those other goods that are 6 mm
or more in diameter. So, since the
difference between these two sections is
just the diameter, I am going to go
through these breakouts under 73
18.15.80 for this presentation. And
under this section, there are breakouts
for set roots, socket screws and cap
screws, we have already gone over cap
and so we will focus on set and socket,
for now.
Setscrews are used when one component has
to be attached within another one
without any protrusions. So, like if
you had a year and a shaft assembly, if
you used a regular hex bolt, the head
may get in the smooth operation of a
gear assembly because it sticks out, so
you would use a set screw that does not
have a head that sticks out and
interfere with the operation of the gear.
Set screws are designed to withstand
rattling in operation and not come
undone. They are fully threaded and
they can be headed or headless and even
the headless ones has a drive, this one
has a slotted drive and this one has a
hex drive. And setscrews have specific
point designs such as these examples.
There is a question about internally
threaded such as opinion, we are going
to get to the other threaded examples
shortly. Then, we move on into the other
breakout under this subheading and at
the first one is for socket screws, there
classified under 7813.15.80 30 if it is
stainless steel and 8030/45 other than
stainless steel. Socket screws refers to
fasteners with recessed holes in the
head, this indentation in the head can
be in the shape of a hex, a square or
some other form and they are intended to
be tightened or loosened with a Alan
wrench or a hex key as opposed to a
traditional screwdriver. So, before we
leave this other screw or bolts
subheading, I want to mention this other
example from a headquarters ruling.
This fastener is called several names,
it could be called a oil bolt or banjo
bolt or pressure fitting, as you can see
it has a hex head, it is threaded,
hollow and it has this whole through a
shaft, so a little different than the
other screws we have been looking at.
It is used solely in breaking systems of
motor vehicles and it functions, the
screw functions to attach the oil feed
line and this whole functions to allow
brake fluid through the hole into the
stem. So, according to the importer,
the brake system would not be functional
without the passage of brake fluid.
Now, clearly this item has two
significant functions. It functions as
a screw, and it allows the flow of brake
fluid, so where do we classify it? Is
it a fastener of 7813 or a part of motor
vehicles in chapter 87? The
explanatory notes state that 7813
includes all types of fastening bolts
and metal screws regardless of shape and
use. So, this item does have a
fastening function, because the threaded
portion here secures tubes, hoses or
lines in the braking system. Because it
has a fastening function, it can be
classified as a screw under 7813.15 E,
because it can be classified under 7813,
it is considered a part of general use
as we talked about at the beginning.
Parts of general use, when they are
entered separately are not considered as
parts of articles, but are classified in
the appropriate heading under section 15
and in this case, the appropriate
heading would be 7813.15.80 as a screw.
And also parts of general use are
excluded from general use classification
by section 17 note 2B and that is where
we would classify a part of a motor
vehicle. And so even this oil bolt may
be specifically designed for use in motor
vehicles or motorcycles, it is
nevertheless still a screw which would
be classifiable in heading 7813 and the
fact that the oil bolt also allows for
the passage of fluids does not negate
the fact that it has a significant
fastening function. Are there any
questions on that before I move on?
Okay, 7813.16 provides for nuts. And
classified under this subheading from
China are subject to 301 trade remedy
than all other fasteners of 7813.
Currently nuts from China are subject to
an additional 7.5% trade remedies whereas
all the other fasteners are subject to
an additional 25% trade remedies.
The subheading for nuts is broken into
two headings, lug nuts and other nuts, if
it is not a lug nut, it would be
classified under the subheading of
other, so let's take a look at what a
lug nut is.
Lug nuts are designed to hold a wheel
onto a vehicle. They interface with the
design of the wheel and many of them
have a conical or tapered seat, because
of that. The statistical breakouts
associated with lug nuts are nonblocking
chrome plated lug nuts which are in
7813. 16.0015 and then you have locking
lug nuts which in in 30 and other lug
nuts which ends in 45.
Other nuts of stainless steel are
provided for in 7813.16.00 60 and other
nuts that are not stainless steel are
provided for in 7813.16.00 85. This is
defined broadly as a type of fastener
that is internally threaded and often,
but not always used opposite a meeting
bolt. It holds the bolt in place and
fastens materials together. Nuts are
usually happen throughout and some
examples include a common nut, this is a
castle nut, a wingnut, a square nut and
a clinch. In these examples, the nut is
torqued onto the meeting bolt, but that
does not appear to be a requirement.
Two examples of that.
Both of these examples are internally
threaded and they function to hold a
bolt in place and thereby fasten
materials together. But, in both of
these examples, the nut is not torqued
onto the bowl, instead, in each case,
the nut is placed in the material that
it will fasten and then it provides a
threaded receptacle for the bolt that is
then fastened into the nut, so they are
a little bit different than a
traditional nut, but they fit into the
router definition which is again a type
of fastener internally threaded and
often used opposite a meeting bolt
holding the bolt in place and thus
fastening the materials together.
Pipefitting nuts are not nuts of heading
7813, they have different features and
intended usages and groups and they are
marketed in different apartments and not
classified in 7813.
The question is, what a flat cushion not
be other or Push cap? I would need to
look at what a flat push not is to answer
that question. 7813.19 provides other
articles that are similar to 7813 but
that are not covered by the previous
subheadings. So, here are some examples.
A hollow wall anchor or a Molly bolt
has a machine screw here, it is within a
separate T shaped anchor with an
internally threaded hollow barrel shaped
them. So, the Molly bolt is inserted
into a predrilled hole where it is
hammered in place and a drill or
screwdriver is used to tighten the screw
expands the anchor into the wall. Once
the anchor is secure, the screw is
removed and the screw only functions to
expand that anchor and then they take it
out. Once the Molly bolt is in place,
you can use the anchor to hang heavier
items on the wall. So, this item is not
a bolt, because it is not designed for
assembly with a nut, it is not a screw,
because it does not mate with a
preformed internal thread or form its own
thread and it is not a study, because it
does not have anything protruding that
can support another object, so it is
classified as 7813.19 as a other threaded
article.
And my other example is the eye lag
screw, this would be screwed into the
ceiling, so that a suspended acoustical
ceiling panel can be secured by wires
included through the eye here. This is
not a screw, because it does not have a
slotted or recessed head and it does not
provide an additional function that is
not associated with screws. It is not a
screw hook or ring because it is not
bent at a right angle and it is not a
study, because the eye cannot mate an
attachment with a nut or other fastener,
therefore it is classified under
7813.19. There is a question, is a stud
bolt a bolt or a Stud bolt? A stud is
technically a type of bolt, but it has a
particular - it needs to be fastened
into a material and have something
protruding out that you can attach a nut
or other fastener too. So, if it meets
that definition, then it would be
classified as a stud, but I would need
to see the item that you are specifically
asking about.
Lastly we are getting into the
non-threaded subheadings. This
subheading breaks out into two different
types of washers. 73 18.21 provides for
spring washers and other lock washers and
7813.22 provides for other washers and
so before the differences, I will cover
the attributes of washers in general.
In general, washers are usually small,
thin discs with a hole in the center and
their place between unknot and one of
the parts to be fixed in place to
increase the bearing surface of a
threaded fastener. Washers function to
protect the part or the material that is
being fastened and it evenly distributes
the weight when you're tightening. So,
helical spring lock washers are designed
to keep the fastener from loosening.
They have this split which gives them the
flexibility and they are also used to
prevent fastening or loosening due to
vibrations. The helical spring lock
washers from China and Taiwan may be
subject to these antidumping cases.
Other spring and lock washers are
provided for in 7813.22.00 90. As you
would expect, locking washers prevent
loosening by preventing unscrewing
rotation of the fastening device. There
are several types of lock washers
including this example as an internal
lock washer and external lock washer,
conical spring washers and wedge lock
washers.
And let's see here - 7813.22 provides for
other washers and examples of washers
that are classified here are flat
washers, finishing, tender, square or
ogee washers.
Rivets are used for the permanent
assembly of metal parts when reliability
and safety are important. They are not
threaded and usually cylindrical in
shape. They are installed by using a
hammer or a rivet gun and that hammer or
rivet gun would form this headless and.
7813.23 includes solid rivets which
have a solid shaft on one end and it
includes tubular rivets which are partly
hollow and you can partly see that in
the picture, it is only partly hollow
and then it gets solid there. But, this
heading excludes tubular rivets that
have a deep hole, it excludes bifurcated
which are split and it includes break
mandrel rivets, those are all classified
in 8308.
Here are those rivets. You have got a
tubular rivet which is also known as a
hollow rivet, they have a hollow shank.
This is a bifurcated rivets, it is also
known as a split rivet, they are pretty
split along the length of the shaft and
that forms these two legs and these
rivets usually require special tools for
installation. And then you have blind
rivets which are also known as break
stemming rivets or break mandrel rivets
or pop rivets, these are tubular
fasteners and have a mandrel through the
center. And I also want to point out
that these rivets that are classified in
8308 are also subject to 301 trade
remedies if they are also from China.
It looks like I had a HDS code mistake
on the last slide here. 20 200 90. I
don't even know what that was. Sorry
about that. Okay, so cotters and cotter
pins are provided for in 7813.24, pins
are used for fitting in holes, spindles,
shaft, bolts and they hold parts
together and this one is a split pin, a
hairpin and a bowtie. A cotter is a
wedge, a pin or a key that is inserted
through a slot or passes through a hole
or fits into a groove or a slot that cuts
around a shaft. They have a similar
function of holding parts together like a
cotter pin, but they are usually bigger
and sturdier and some examples of those
would be paper pins, axle keys and
Woodruff keys.
Cirque clips are also placed under
7813.24 and used to prevent lateral
movement and they can be really simple
with a gap to more complex shapes and
some of these include this one is a
internal or slightly open circlips and
this one is a E hype circlips.
Non-threaded fasteners that are not
classifiable under the previous
subheadings are classifiable in 7813.29.
The cleavage pain is an example and
here are two different examples of one,
it performs a fashioning function, it is
not threaded, but it is not a washer or
a rivet or a cotter or a cotter pin, so
it will go under a non-threaded fastener
and just as an example, here is a clevis
pin through the center here and actually
this is a cotter pin here that holds the
clevis in place. Pension pins would be
for another example of non-threaded
fasteners and they are hollow and slotted
and the diameter is a little bit bigger
than the diameter it will go into and
once it is installed it pushes against
the perimeter to secure it in place.
This top example is a steel bolt that has
two flattened sections on opposite side
of the shank, so because the threading
is flattened, the threading does not form
a helix and therefore not considered a
threaded fastener. A speed not on the
bottom here is used on threaded
fasteners, but it cannot be classified
as a nut, because it does not have a
complete thread in here, so it is
classified here as a other non-threaded
fastener. There
is a informed compliance publication
that provides guidance on the fasteners
of 7813 that you can also reference in
addition to this slide deck and just to
let you know we are currently updating
that ICP.
So, that is all I have for you. Before I
get into questions, I just want to thank
my associate, Richard Schueler for his
help on this presentation and also the
webinar team that made this
electronically possible and that is
Sandra Walia, Fung King Kong, Amy
Purkett (SP?) and Lynn Banks. Contact
information for Richard and me is on the
screen if you have questions outside of
this forum, you can reach out to us at
these email addresses. And with that,
do you have any questions for me?
Okay, I am seeing a couple - let me get
to where I can see - I lost my chat
here, sorry about that, let me get it
back. Okay, sorry, I am trying to get
where I saw a number of one's where you
wanted to see certain pages, let me get
back there. Okay, my thumbnails are not
showing up here. Okay - okay, let's go
with there were a number of pages that
we wanted to go back to and I am just
going to go where I see those slides,
33. I also see a slide nine.
>>SPEAKER: There is also 22 and 38
they have requested.
>>JENNIFER JAMESON: Thank you, here
is 22. Here is 38. I just saw 39.
>>SPEAKER: Also, do articles of 7813
require an import steel license
permit?
>>JENNIFER JAMESON: import steel
license permit - I do not think so. I
have not worked with one of those, so I
would say no. Thank you, Ed, who thought
my presentation was riveting and did my
basic training years ago! I am seeing
slide 11 and a question. And 42. And
43.
>>SPEAKER: There is also a question,
what a linchpin considered the same as a
cotter and?
>>JENNIFER JAMESON: I would have to
see what a linchpin looks like that you
are talking about the answer that if you
want to email me separately, I can take
a look at it. Our rivets that are
threaded still considered rivets and
under what classification, 73 or 83 ? I
would need to see what rivet you are
talking about, if it has a fastening
function - I would need to see it, I am
sorry. Yes, I cover the difference
between a screw and a bolt and that was
early on, I would guess around here and
let me find it - here is the difference
between bolts and screws, this is a basic
overview, you should look at the
distinguishing bolts from screws ICP for
the specifics, because if the fastener
has more characteristics of a screw, then
it will be a screw. There is a
question, are speed nets also known as a
Steel clip? I believe they are. I have
a IOR claimed as a bolt used as a spare
part on a helicopter is 8803, but it is
just a regular part, only more
expensive, absolutely 7813. If they can
meet the definition of a bolt or any
fastener in 7813, and it is coming in by
itself, it would be classified under
7813, absolutely. I am seeing slide 47.
There is a question if a hardware kit
is imported separately with multiple
washers, nuts, bolts of different sizes,
do we need to classify each item in the
kit separately? So, I think then we are
going to have to look at is a going to
be a set for Terrace purposes and if it
is, if for example it is a hardware kit
to put together a specific piece of
furniture, then we can go by what is the
essential character of the set, so maybe
there is you know 30 bolts and two
washers, it would be classified by that
bolt. Or it could be classified by
tariff if they are all equally important.
If it is not a set, then yes, you will
have to classify them all separately. I
am just going to look through some of
these. Okay, so there is a pin with a
little ball mechanism at the bottom, okay
and she said - he says I used to
classify them as 8302, a lock mechanism
without a key, do you have any criteria
about this? So, a lock of 3302 need
thick meat or some kind of electronic
way to open and I don't think that this
item if I am thinking of the correct
one would not need one, so I think more
than likely it will go in 73, but if you
can send me a picture, I can look at it
and get you a better answer than that.
I think I have shown some of these
slides, but I'm going backwards to
answer everybody. Slide 14 - I have got
slide 36 - I do not think I have shown
57. And again, these slides will be
available in about 2 to 3 weeks when
this is posted. Okay, I'm going
backward and somebody is asking about a
recording of the webinar, yes it will
absolutely be available. Okay, so I
think I have gone through all the
questions backwards and I will see if
anything new has come in. A shop class
for trade nerds, what a hardware kit be
entered as co-mingled goods? I would
need more information about that one.
In 22 used in chapter 90, medical
equipment, is that still a general use
fastener? I think it would not, that is
off the top of my head, I know a
surgical screw like a dental screw or a
bone setting screw are classified in 90
and in those would not be general use,
so I would think it would be that way
with circlip's, but that is where I
would start from as I look for that
question and I am thinking about it, but
it looks like it. Somebody, Lan (SP?)
you sent me a link that I cannot open,
if you sent me an email I would be happy
to answer your question about a
non-threaded article or a nut, if you
can email that to me and I'll put that on
my - I will put that on my contact
information, oh my goodness - there. If
you can send me that in an email, then I
will be able to answer that question.
Another question, our aircraft nuts and
bolts classified in 7813? So, if they
are entered separately and if they can
meet the definition of a nut or a bowl as
we just described in 7813, then yes,
they would be classified under 7813 and
not a part of the aircraft, because they
would be parts of general use and there
are a number - so, parts of general use
entered separately are not considered a
part of an item.
I think I have got all the questions. I
will give it another minute unless there
is anything else. Okay, I am not seeing
anything, but if I did not answer your
question or you had more questions,
please feel free to email me at my email
address that is on the screen there and
I would be happy to look into your
question. Thank you, so much, I really
appreciate your time!
>>SPEAKER: Thank you, Jennifer, we
hope that you found today's webinar very
informative comedy continuing education
credit code was placed in the WebEx chat
and it will be emailed to all of the
participants who logged into today's
webinar via their email address within
48 hours. As Jennifer mentioned,
today's webinar will be posted on
CBP.gov under the trade outreach
webinars in the coming weeks. Thank you,
everyone for joining us today and this
afternoon, everyone! R